Proposed Revision Request Detail Help
PRR Life Cycle*********Closed
PRR Details
Title Commitment cost enhancement tariff clarification process policy initiative
Date Submitted 12/28/2020 1:03 PM
PRR Category C
Priority Normal
Owner Schimschal, Melanie (CAISO)
Status Closed
Status End Date 4/13/2021 11:59 PM
Related BPM Reliability Requirements
BPM Section 7.1.1,10.1.1,10.3.4, Exhibit A-1
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Existing Language
Please see attached redline.
Proposed Language
Please see attached redline.
Reason For Revision
Clarifications made for Commitment cost enhancement tariff clarification process policy initiative
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BPM PRR Submitter

Schimschal, Melanie (CAISO)
Modified BPM language proposed by the PBM Chnage Management Coordinator

Please see attached redline.
Identification of the authorship of comments


Approve the BPM PRR as modified.

Approve the BPM PRR as modified.
Statement of apparent requirements of the BPM PRR

Priority and rank for any BPM PRR requiring a CAISO system change

Proposed effective date(s) of the BPM PRR

Other recommended actions

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Final Decision

Approve the modified version.
Stakeholder Comment


Effective Date


Adopt the recommendation as modified

PRR 1315 has been made available at this time to allow additional time to review and submit comments. 
Comment period will close 02/16/2021.  PRR will be discussed during the February and March BPM meetings
Posted On - 1/12/2021 10:09 AM
Impact Analysis
Impact Analysis not available.
Initial Comments
• PG&E recommends that CAISO delete language in Section (4) and Section 7.1.3 which states: “Where the expected energy or expected as-available energy is below the RA Capacity quantity, the Scheduling Coordinator must notify the CAISO of that shortfall using the “Ambient Not Due to Temp” outage card to avoid a substitution obligation and RAAIM exposure.” The CAISO is proposing to remove similar language related to the “Ambient Not Due to Temp” card in PRR1314.
• PG&E recommends applying the “as available” MOO to all hydro resources, referencing our comments in Phase 2A of the RA Enhancements initiative:

"PG&E and the CAISO successfully worked together to create a paradigm to reevaluate the QCs for hydro resources. Under this system, the inability to operate for water conditions will show up in future QCs. However, it does not make sense for hydro to have a MOO up to this calculated DQC.

In the 6th Revised Draft Proposal, the CAISO says they will “apply the standard must offer obligation to use-limited resources and conditionally available resources, unless the underlying technology has a different offer obligation.”  The CAISO further states “Conditionally available resources are also able to use outage cards to manage their conditionally available outages and derates.”  Having a must offer obligation and using outage cards for Hydro resources does not make sense. For example, it appears that the CAISO expects outage cards to be submitted for CAR resources to reflect their as-available must-offer obligation, which tells the CAISO nothing about the potential for that resource to provide more capacity under an exceptional dispatch scenario. Mandating cards creates additional work for PG&E hydro operators and CAISO operators without achieving any reliability gains.
The CAISO needs to accommodate the physical realities of the hydro system. The CAISO has attempted this multiple times: first in Commitment Cost Enhancements Phase 3 (CCE3) by creating use limited status, then with the creation of CAR status, and, most recently, the implementation of Run of River status. PG&E has spent a significant amount of staff time working with the CAISO to try and respond to these changes, but none of them accurately address the nuances of the hydro system. PG&E appreciates the need for the CAISO to understand what resources they have available but adding must-offer obligation language for hydro would shoehorn these resources into a system which does not work for them.

The CAISO should take the following actions to address this problem:
Revise the language in the must-offer obligation section to have all hydro submit bids for energy or as available energy up to the RA quantity. This would the existing CAR language to all resources with the hydro QC based on historical exceedance, but not those that choose to have a QC above the historical exceedance calculation.
Consider tools other than OMS to reflect water availability. All of the same reasons that make outage cards not a viable tool for hybrid resources apply to hydro (for availability due to water conditions). The use of outage cards for hydro resources continues to be appropriate for mechanical outages, but not for water availability."

• PG&E requests clarification on changes made to “Pumping Load without qualifying use limits”—the proposed language by default will exclude the category of “Pumping Load with qualifying use limits”. The CAISO should add this line item and apply the original (unedited) MOO for Pumping Load.
2/16/2021 10:31 AM
Logged By - MichaelVolpePGE (Pacific Gas & Electric Company)
Recommendation Comments
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